mmpc - National Indian Health Board

mmpc - National Indian Health Board mmpc - National Indian Health Board

06.03.2013 Views

i. CMS stated on a couple of occasions that states have the ability to apply additional standards on QHP than the minimum standards established by CMS - Imposing a requirement that all QHP’s in a state Exchange must offer to contract with I/T/U would be allowable. ii. CMS stated they would need to issue additional formal regulations if the FFE were to impose additional requirements on QHP, such as requiring a plan to offer to contract with each I/T/U. - CMS staff also indicated that, while it is not certain and they didn’t offer to include any AI/AN-specific provisions if they do, it is likely that CMS will be issuing further formal guidance on the FFE. f. Who should tribes engage in tribal consultation with regarding Exchange operations? i. For state-based Exchanges, state officials. ii. For strictly FFE, engage CMS but no explanation was given yet of how tribes will engage CMS on state-specific issues that may apply solely to one specific state FFE (versus the discussions going on now between TTAG and CMS on the national FFE design.) iii. For Partnership exchanges, engage states on the specific functions a state may decide to operate. - Plan management (e.g., certification of QHP) - Outreach and enrollment assistance (e.g., Navigator program and “in-person assistance”) g. Liability for tax penalty for certain IHS beneficiaries - In response to questions, the IHS Director and CMS staff acknowledged that some IHS beneficiaries who choose not to purchase health insurance coverage and who do not meet the definition of Indian under the IRC definition could be liable for the tax penalty administered by the IRS for not having “creditable coverage”. h. Analysis of impact of Medicaid expansion on states 7

i. CMS rep. commented that an analysis is underway to determine the impact on each state from exercising the new Medicaid expansion option, but the analysis isn’t complete. - It wasn’t clear if CMS or another party was doing the analysis. - CMS rep. noted that it looks as if the Medicaid expansion will prove to reduce some/many state’s overall local expenditures. ii. CMS rep. cited statistics for a select number of states on the reduction in the percentage of uninsured persons in the state solely from a state exercising the new Medicaid expansion option (up to 138%). The data source was not cited. - Montana: 66% - North Dakota: 67% - South Dakota: 50% - Oklahoma: 74% - Arizona: 65% i. For non-expansion states, in response to questions raised in Anchorage and Denver -- i. CMS commented “We would be very interested in waiver proposals” from states/tribes designed to expand Medicaid coverage solely to AI/AN through I/T/U, possibly structured similar to the approved approach for AI/AN-specific benefits in Arizona. ii. CMS is considering developing a template for states to use in requesting a waiver to extend Medicaid coverage to AI/AN. j. State Plan Amendment or waiver request to CMS i. CMS emphasized that tribes in a state have the ability to request tribal consultation directly with CMS if they are not satisfied with the tribal consultation process and outcomes undertaken with the state. 8

i. CMS rep. commented that an analysis is underway to determine<br />

the impact on each state from exercising the new Medicaid<br />

expansion option, but the analysis isn’t complete.<br />

- It wasn’t clear if CMS or another party was doing the<br />

analysis.<br />

- CMS rep. noted that it looks as if the Medicaid expansion will<br />

prove to reduce some/many state’s overall local<br />

expenditures.<br />

ii. CMS rep. cited statistics for a select number of states on the<br />

reduction in the percentage of uninsured persons in the state<br />

solely from a state exercising the new Medicaid expansion option<br />

(up to 138%). The data source was not cited.<br />

- Montana: 66%<br />

- North Dakota: 67%<br />

- South Dakota: 50%<br />

- Oklahoma: 74%<br />

- Arizona: 65%<br />

i. For non-expansion states, in response to questions raised in<br />

Anchorage and Denver --<br />

i. CMS commented “We would be very interested in waiver<br />

proposals” from states/tribes designed to expand Medicaid<br />

coverage solely to AI/AN through I/T/U, possibly structured<br />

similar to the approved approach for AI/AN-specific benefits in<br />

Arizona.<br />

ii. CMS is considering developing a template for states to use in<br />

requesting a waiver to extend Medicaid coverage to AI/AN.<br />

j. State Plan Amendment or waiver request to CMS<br />

i. CMS emphasized that tribes in a state have the ability to request<br />

tribal consultation directly with CMS if they are not satisfied with<br />

the tribal consultation process and outcomes undertaken with the<br />

state.<br />

8

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